Munoz v. Watsonville Cmty. Hosp. — June 2016 (Summary)

EMTALA

Munoz v. Watsonville Cmty. Hosp.
Case No. 15-cv-00932-BLF (N.D. Cal. June 2, 2016)

The United States District Court for the Northern District of California granted with leave to amend a defendant-hospital’s motion to dismiss Emergency Medical Treatment and Active Labor Act (“EMTALA”) claims brought by a plaintiff-patient for failure to stabilize and disparate treatment.

The patient alleged that after being identified as having an emergency medical condition, the hospital failed to stabilize the condition because she received treatment for a mental condition instead of treatment for abdominal pain.  The court noted that if a hospital detects an emergency medical condition, it has a duty to stabilize, but EMTALA does not impose liability on a hospital that misdiagnoses the condition.  The court found that, in this case, plaintiff’s allegations appear to rest on a misdiagnosis and, if so, that would not be actionable under EMTALA.

The patient also claimed she received disparate treatment.  The court noted that the plaintiff’s claim appears to be based on her not being given an appropriate medical screening examination required by the appropriate standard of care.  However, the court found that the “measuring stick” for disparate treatment is not the standard of care, but what treatment other patients that had the same condition would have received at the hospital.  Since the patient did not allege that she received different treatment than others presenting with the same condition, she did not state a claim under EMTALA.